12 replies to this topic

[Sanslife]

Hi all,

If i have 2 metal detector in same line, first one for naked product (higher sensitivity) and second one for packed product (lower sensitivity). Which one is OPRP and which one is CCP? 

1st auditor: You need to use 1st MD as CCP and 2nd MD as OPRP /CP because 1st MD is the most sensitive and there is no further process that can eliminate the same hazard. 2nd MD is to eliminate metal from packaging and not product.

2nd auditor: You need to put 1st MD and 2nd MD as CCP because last MD cannot be a OPRP. The last MD is not sufficient to become CCP because the sensitivity is not enough and you need to upgrade to X ray.

The question is:

1. Can OPRP placed after CCP point?

2. If the MD is intended for packaging only and act as precaution measurement, can we consider it as normal CP instead of OPRP or CCP.

Please share your thought.  Thank you.

 

[KevinR]

We have similar situation, but sensitivity is the same on both. What is the sensitivity of the second detector? If it is sensitive enough to reduce hazards to acceptable level ie industry standards, the it would be CCP as it is the last point of control. Ist detector is CP as it is not really required. If it came up in an audit I would argue that I do not even need to have the 1st detector in place and the hazards would still be controlled, therefore it cannot be a CCP.

[RG3]

I agree with Kevin,

   

   Your last metal detector is your last point of defense. If your saying in your Hazard Analysis that there still remains a risk after the first metal detector, your last metal detector becomes a CCP. Your first metal detector a CP.

 

I have had the opposite happen to me where I called both my metal detectors CCP's. An auditor said my last metal detector is my CCP. However my last metal detector was more sensitive which is different from your case. However, once again Kevin is correct when saying it depends if your last metal detector is acceptable to industry/legislative standard you would still be correct to name your last metal detector as a CCP and/or vice versa.

[Charles.C]

Dear Sanslife,

 

I think the previous posters have well defined the situation.

 

Basically the direct hazard is (unremoved)  "metal" from the consumer's POV.  But what actually constitutes "hazardous"  metal is globally disputed.

 

For example, in Canada, from memory, >= 2mm is unacceptable. I would hope that yr MD sensitivity would match that requirement for a sphere  or else you need  better equipment, unless perhaps 50kg sacks are involved ?

What is the Malaysian standard ?

 

IMO neither MD installation is an OPRP but this may simply depend on yr criteria. 

 

Rgds / Charles.C

[Sanslife]

Hi,

 

1st MD is Fe:> 1.2mm, Non Fe: > 1.5mm, Sus: > 2.0mm

2nd MD is Fe:> 2.5mm, Non Fe: > 5.0mm, Sus: > 6.0mm (reason being is the effect of metalized film wrapper)

 

Actually for us, the risk of the metal contaminant to contaminate the product after the 1st MD is very small. The reason of 2nd MD is to reduce the risk of having metal contaminant from the packaging material (film, box, tray, bag).

 

This is some point that we argued:

1. The last metal detector intended for eliminating metal hazard from the product are the metal detector for naked product

2. The metal detector which located after the wrapping process is not intended for the product but to act as a precaution measurement for eliminating potential metal in the packaging material (tray, boxes, wrapper) which does not poses risk to contaminate the cookies itself.

3. There is no risk of having metal hazard to contaminate the cookies after the last metal detector (naked product) as it is well protected along the process until it was packed.

4. Based on historical data, there is no incident where the second metal detector detect any metal in the cookies.The last metal detector intended for eliminating metal hazard from the product are the metal detector for naked product.

It just doesn't feel right putting a less sensitive metal detector as CCP point.

[Mr. Incognito]

A CCP is the last control to remove a hazard or reduce it to an acceptable level that without it's control the hazard is reasonably likely to cause illness or injury.

 

So the question really is if there is ANY chance a piece of hazardous metal can be introduced into your product after the first metal detector.  If the risk of that is high enough then the 2nd metal detector is your CCP.  If there is no risk of a hazardous piece of metal being introduced after the first metal detector than the 1st metal detector is your CCP.

[Sanslife]

I agree with you Mr.Incognito. The hazard after the first metal detector had been manage by preventive maintenance and cover along the route. The only possible metal contaminant is coming from the packaging material. That is the reason why we put it as oprp as it would not contribute high risk toward the product. But somehow there is auditor think that it should be CCP for both and we need to upgrade the 2nd MD to x ray.

[Mr. Incognito]

I agree with you Mr.Incognito. The hazard after the first metal detector had been manage by preventive maintenance and cover along the route. The only possible metal contaminant is coming from the packaging material. That is the reason why we put it as oprp as it would not contribute high risk toward the product. But somehow there is auditor think that it should be CCP for both and we need to upgrade the 2nd MD to x ray.

 

Well the entire HACCP program is based on perceived risk and what you need to do to mitigate that risk.  If you have rated the risk of metal coming off of the equipment after the 1st metal detector as low enough that that it doesn't require a CCP your auditor is wrong.  Not every metal detector needs to be a CCP.  What justification did he give you that you needed an X Ray machine?  I would make the 2nd one an oPRP and tell him that's your system personally.

[fgjuadi]

Is there something stopping you from putting the more sensitive metal detector 2nd or not even using a second detector?

Maybe your second detection for packaging is more of a QCP ...

Edited by magenta_majors, 04 November 2014 - 02:23 PM.

[Mr. Incognito]

Is there something stopping you from putting the more sensitive metal detector 2nd or not even using a second detector?

Maybe your second detection for packaging is more of a QCP ...

 

In FSSC there isn't a requirement to have QCPs like in SQF level 3.  That's why I said it might be better to classify it as an oPRP which could be prevention of contaminated packaging or something.  An oPRP in FSSC can be considered to be like a CP in other food safety management systems.

[Charles.C]

Dear Sanslife,

 

The reason why people prefer to locate a  MD/CCP following the “product” enclosing point is self-evident.

 

Foil wrapped food not my speciality but the MD producers seem to well agree  with yr focussing on the first MD unless, as yr sensitivity data indicates, you only consider ferrous metal to be the significant hazard which i guess is not the case.

 

 md1 - Loma - Guide_to_Metal_Detection.pdf   465.03KB   147 downloads

 

Although i suppose the company might consider investing in an X-ray unit if there is a determination to monitor at a later position.

 

Rgds / Charles.C

[fgjuadi]

In FSSC there isn't a requirement to have QCPs like in SQF level 3.  That's why I said it might be better to classify it as an oPRP which could be prevention of contaminated packaging or something.  An oPRP in FSSC can be considered to be like a CP in other food safety management systems.

Agreed that the FSSC has no quailty requirement....but if you made it an oPRP, you would be saying that it is controlling a food safety risk with a program.  oPRPs are generally programs that are monitored for effectiveness, where as CCPs are actual steps that are verified continuously.    Perhaps if there is metal in the outer case but not in product, it is more of a quality issue than a food safety issue.  If you agree the metal detector is there for food safety, then you follow the ISO decision tree.   If the first metal detector eliminates the hazard, why do you need a second metal detector?  If the first metal detector doesn't eliminate the hazard, then the second metal detector is the critical point - the last step in the process you detect that hazard & control.   If you keep both the first metal detector could be an oPRP (because it is there to control a specific hazard, but there are steps further on in the process to control the same hazard) and the second could be the CCP. 

Edited by magenta_majors, 04 November 2014 - 05:20 PM.

[Charles.C]

Dear All,

 

It’s an interesting discussion on what might constiute the criteria for a  “non-safety related oprp” but the post is in the FSSC22000 safety arena. And perhaps Malaysia has local regulatory standards regarding metal contamination in foods which would then prioritize as far as “acceptable level” is concerned.

 

As currently stated, the texts of  ISO22000 / ISO22004, permit a vast range of interpretations regarding –

 

(a) Criteria regarding whether a control measure should/could  be classified within the CCP/OPRP domain.

(b) if  the result of (a) is yes, the criteria regarding  whether the CM should be associated with a  CCP or OPRP.

© Crteria for validation/verification of the control measure’s ability to acceptably control the hazard.

 

AFAIK, auditors require to see a documented interpretation of the standard enabling the  presentation of  criteria for (a,b,c) which seem “logical”, ie can be “validated” (somehow/somewhere/somewhen).

 

At one time, some posters here noted that their auditors were unhappy at “simple” methods largely based on use of  the traditional Codex Decision Tree but this aversion seems no longer evident.

 

One might consider that the chosen method for finding OPRPs  depends on whether few or many CCPs/OPRPs in total are preferred by the user, a route which has some historical haccp echoes.

 

ISO itself sits nicely on the fence in ISO22004 which indicates that the ratio of CCPs to OPRPs  is effectively irrelevant.

 

George Howlett’s (Safefood) White paper / blog /  webinar nicely illustrates/compares some of the OPRP options involved in a user-friendly way although not exclusively oriented to ISO22000. From memory, the White paper includes a discussion on metal detectors as CCPs/OPRPs.

 

Personally, it seemed to me that the OP had already concluded that the implementation of the  2^nd MD was unrelated to a significant food hazard. Therefore, in my ISO interpretation,  neither a CCP nor an OPRP. And equally for a 3^rd MD if added.

 

One could opine that the addition of a final X-ray unit would validate the use of the first MD on its own (assuming X-ray has equal/better sensitivity to MD ?). Or enable removal of both MDs?. And satisfy the auditor ?

 

Rgds / Charles.C